§2051 — Definition of taxable estate

Applicable Law Section 2001(a) imposes a tax "on the transfer ofthe taxable estate ofevery decedent who is a citizen or resident ofthe United States." Section 2051 provides that the value ofthe taxable estate is determined by subtracting allowable deductions from the value ofthe gross estate.

iples The Code imposes a tax on “the transfer of the taxable estate of every decedent who is a citizen or resident of the United States,” sec. 2001(a), and it defines the taxable estate as “the value of the gross estate” less applicable deductions, sec. 2051. The value of the gross estate of a decedent is “the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated,” to the extent provided in sections 2033 through 2045. Sec. 2031(a). Section 20

Section 2051 provides that, for purposes of the tax imposed by section 2001, the value of the taxable estate is determined by deducting from the value of the gross estate allowable deductions. The gross estate of a decedent who is a citizen or resident of the United States is determined in accordance with chapter 11, subchapter A, part III, of the

Section 2051 provides that, for purposes of the tax imposed by section 2001, the value of the taxable estate is determined by deducting from the value of the gross estate allowable deductions. The gross estate of a decedent who is a citizen or resident of the United States is determined in accordance with chapter 11, subchapter A, part III, of the

The Time of Death as Valuation Date Section 2031(a) provides that the gross estate is generally valued at the time of the decedent’s death.

The gross estate sweeps up the value of any property in which a decedent had an interest at the time of his death. I.R.C. § 2033. Allowable deductions include (1) the amounts of any bequests, legacies, devises, or transfers for certain recognized charitable purposes, I.R.C. § 2055, and (2) the value of property passing from a deceden

The value of the gross estate generally includes the fair market value of all property that the decedent owned on the date of death or that is otherwise included in the gross estate under the Code. See I.R.C. §§ 2031, 2033–2046; Treas. Reg. § 20.2031-1. If a decedent made an inter vivos transfer of property (other than a bona fide sa

1937); see also Estate of Pollard v.

The gross estate generally includes the value of property described in sections 2033 through 2044. See Treas. Reg. § 20.2031-1(a). Under section 2033, a decedent’s gross estate includes the value of all property beneficially owned by the decedent at the time of death. See Treas. Reg. § 20.2033-1(a). The value of an estate includes, among ot

Section 2053(a)(3) provides that “claims against the estate” may be deducted from the value of the gross estate.

The gross estate includes “all property, real or personal, tangible or intangible, wherever situated’’, to the extent provided in sections 2033 through 2045. Sec. 2031(a). Section 2033 is a broad inclusion provision and includes the value of all property in the gross estate to the extent of the decedent’s interest in the property at the

A decedent's gross estate includes the value ofany propertythat a decedent had an interest in at the time ofhis death. Sec. 2033. Sections 2034 through 2045 tell us what other property to include in an estate. Some taxpayers reduce their estate-tax liability by making inter vivos transfers several years before their death¹² and pay a usu

A decedent's gross estate includes the value ofany propertythat a decedent had an interest in at the time ofhis death. Sec. 2033. Sections 2034 through 2045 tell us what other property to include in an estate. Some taxpayers reduce their estate-tax liability by making inter vivos transfers several years before their death¹² and pay a usu

Section 20.2056(a)- 2(b)(1), Estate Tax Regs., provides that "[a]ny property interest which passed from the decedent to his surviving spouse is a 'nondeductible interest' to the extent it is not included in the decedent's gross estate." In respondent's view, because the postdeath income was not included in the gross estate here, it cannot increase the marita

The value ofa decedent's gross estate generally includes the fair market value ofthe property owned by the decedent on the date ofdeath or included in the decedent's gross estate under the Code. See secs. 2031(a), 2033, 2036, 2038; sec. 20.2031-1(b), Estate Tax Regs. In general, section 2036 includes property in a decedent's gross estate

The Federal Estate Tax Section 2001(a) imposes a tax "on the transfer ofthe taxable estate ofevery decedent who is a citizen or resident ofthe United States", and section 2051 defines the taxable estate as "the value ofthe gross estate", less applicable - 11 - deductions.

The Federal Estate Tax Section 2001(a) imposes a tax "on the transfer ofthe taxable estate ofevery decedent who is a citizen or resident ofthe United States", and section 2051 defines the taxable estate as "the value ofthe gross estate", less applicable - 11 - deductions.

The value ofa decedent's gross estate includes the fair market value ofthe property owned by the decedent on the date ofdeath. - 13 - [*13] Sec. 2031(a); sec. 20.2031-1(b), Estate Tax Regs. Fair market value for this purpose is the price at which property would change hands between a willing buyer and a willing seller, neither being und

Except to the extent provided in sections 2033 through 2046, the gross estate includes "all property, real or personal, tangible or - 7 - [*7] intangible, wherever situated." Sec. 2031(a). The value ofthe gross estate includes the value ofsuch property, to the extent ofthe decedent's interest in it, at the time ofdeath. Sec. 2033. Secti

milarly to a mark- - 27 - to-market tax when the mark-to-markettax is imposed on zero-basis assets. Compare sec. 2001(a) (imposing a tax "on the transfer ofthe taxable estate of every decedent who is a citizen or resident ofthe United States"), and sec. 2051 (defining the value ofa taxable estate as the value ofthe gross estate less certain deductions provided for in the estate tax), and sec. 2031 (defining the value ofa gross estate as the value at the time ofdecedent's death "ofall property, r

A decedent's gross estate includes all property to the extent ofthe decedent's interest in the property at the time the decedent died. Sec. 2033. A decedent's gross estate may include real property, tangible personal property and/or intangible personal property. Sec. 20.2033-1(a), Estate Tax Regs. The value ofevery item ofproperty includ

The gross estate includes the value ofall property that Mr. Adell owned on the date ofdeath. Sec. 2031. Generally, the value ofthe gross estate is the fair market value ofthe included property as ofthe date ofdeath. Sec. 20.2031-1(b), Estate Tax Regs. Fair market value is the price at which propertywould change hands between a willing bu

Section 2051 defmes the taxable estate as "the value ofthe gross estate", minus any applicable deductions. The gross estate includes "all property, real or personal, tangible or intangible, wherever situated", to the extent provided in sections 2033 through 2045. Sec. 2031(a). The gross estate's value is determined "at the moment ofdeath", see Ahma

Includability ofAssets in Decedent's Gross Estate Section 2051 defines the term "taxable estate" as "the value ofthe gross estate", less applicable deductions.

All bare references to sections are to the Internal Revenue Code in effect for the relevant time.) 5 Section 2001 imposes a tax on "the transfer ofthe taxable estate ofevery decedentwho is a citizen or resident ofthe United States." Section 2051 defines the taxable estate as "the value ofthe gross estate" less any applicable deductions.

Section 2033 broadly provides that the "value ofthe gross estate shall include the value of all property to the extent ofthe interest therein ofthe decedent at the time ofhis - 23 - [*23] death." Sections 2034 through 2045 then explicitly mandate inclusion of several more narrowly defined classes ofassets.

Section 2031(a) specifies that the gross estate comprises "all property, real or personal, tangible or intangible, wherever situated", to the extent provided in sections 2033 through 2045 (i.e., subtitle B, chapter 11, subchapterA, part III of-the Code). Section 2033 provides broadly that "The value ofthe gross estate shall include the v

General Rules and Section 2042(2) Section 2001(a) imposes a tax "on the transfer ofthe taxable estate ofevery decedent who is a citizen or resident ofthe United States." Section 2051 defines the taxable estate as "the value ofthe gross estate" less applicable deductions.

Gene ally, section 2001(a) imposes a tax "on the transfer ofthe taxable estate ofevery decedent who is a citizen or resident ofthe United States." Section 2051 defines the taxable estate as "the value ofthe gross estate" less applicable deductions.

Generally, section 2001(a) imposes a tax “on the transfer of the taxable estate of every decedent who is a citizen or resident of the United States.” Section 2051 defines the taxable estate as “the value of the gross estate” less applicable deductions.

Statute and Regulations Section 2001(a), as of the relevant dates of death in this case, imposes an estate tax on the taxable estate of a decedent, determined, in accordance with section 2051, after deductions provided for in sections 2053 through 2058.

Section 2031(a) provides that the gross estate includes "all property, real or personal, tangible or intangible, wherever situated", to the extent provided in sections 2033 through 2046.

OPINION Section 2001(a) imposes a tax "on the transfer of the taxable estate of every decedent who is a citizen or resident of the United States." Section 2051 defines the taxable estate as "the value of the gross estate" less applicable deductions.

Section 2031(a) specifies that the gross estate comprises "all property, real or personal, tangible or intangible, wherever situated", to the extent provided in sections 2033 through 2045. Property is included in the gross estate at its fair market value, which is "'the price at which the property would change hands between a willing buy

The Claimed Deduction Based Upon the Alleged Agreement and Alternatively Quantum Meruit Section 2051(a) provides that the value of the taxable estate shall be determined by deducting from the value of the gross estate such amounts for claims against the estate and administration expenses as are allowable by the laws of the jurisdiction under which the estate is being administered.

Section 2051 defines the value of the taxable estate as the value of the gross estate minus the estate tax "deductions. The'value of the gross estate is "determined by including to the extent provided for in * * * [sections 2031 through 2046] , the value at the -time - of * * * [the decedent's] death of all property, real or personal, tangible or i

Statute and Regulations Section 2001(a), as of the relevant dates of death in this case, imposes an estate tax on the taxable estate of a decedent, determined, in accordance with section 2051, after deductions provided for in sections 2053 through 2058.

Section 2051 defines "taxable estate" as the gross estate minus certain enumerated deductions (for example, a marital deduction) . Section 2013(b) does not authorize deducting from the taxable estate of the transferor the applicable exclusion amount or any other amount besides death taxes . Our conclusion finds support in the changes that section .

Section 2051 defines “taxable estate” as the gross estate minus certain enumerated deductions (for example, a marital deduction). Section 2013(b) does not authorize deducting from the taxable estate of the transferor the applicable exclusion amount or any other amount besides death taxes. Our conclusion finds support in the changes that section 201

General Rules Section 2001(a) imposes a tax "on the transfer of the .taxable estate of every decedent who is a citizen or resident of the United States", and section 2051 defines the taxable-estate- as "the value .of the gross estate", less applicable deductions .

General Rules Section 2001(a) imposes a tax "on the transfer of the .taxable estate of every decedent who is a citizen or resident of the United States", and section 2051 defines the taxable-estate- as "the value .of the gross estate", less applicable deductions .

General Principles Section 2001(a) imposes a tax "on the transfer of the taxable estate of every decedent who is a citizen or resident of the United States ." Section 2051 defines the taxable estate as "the value of the gross estate" less applicable deductions .

General Rules Section 2001(a) imposes a tax "on the transfer of the .taxable estate of every decedent who is a citizen or resident of the United States", and section 2051 defines the taxable-estate- as "the value .of the gross estate", less applicable deductions .

General Principles Section 2001(a) imposes a tax "on the transfer of the taxable estate of every decedent who is a citizen or resident of the United States ." Section 2051 defines the taxable estate as "the value of the gross estate" less applicable deductions .

The gross estate includes the value of all property owned by a decedent at the time of death. Sec. 2031. In most instances, the value of the gross estate is the fair market value of the included property as of either the date of death, or the alternate valuation date under section 2032 if elected by the executor as is the case here. Sec.

The gross estate includes the value of all property owned by a decedent at the time of death. Sec. 2031. In most instances, the value of the gross estate is the fair market value of the included property as of either the date of death, or the alternate valuation date under section 2032 if the personal representative elects, as Natalie di

Decedent’s gross estate includes the fair market value of all property to the extent provided in sections 2031 through 2046. See sec. 2031. For purposes of this computation, the 17 Petitioners argue that decedent gave away a 48.5502- percent limited partnership interest in the LRFLP more than 3 years before her death. Petitioners explain

The gross estate includes the value of all property owned by a decedent at the time of death. Sec. 2031. In most instances, the value of the gross estate is the fair market value of the included property as of either the date of death, or the alternate valuation date under section 2032 if the personal representative elects, as Natalie di

Decedent’s gross estate includes the fair market value of all property to the extent provided in sections 2031 through -23- 2046. See sec. 2031. For purposes of this computation, the parties dispute whether section 2036(a) applies to the residence. In relevant part, section 2036(a) provides: SEC. 2036. TRANSFERS WITH RETAINED LIFE ESTAT

The gross estate includes the value of all property owned by a decedent at the time of death. Sec. 2031. In most instances, the value of the gross estate is the fair market value of the included property as of either the date of death, or the alternate valuation date under section 2032 if the personal representative elects, as Natalie di

Section 2031(a) specifies that the gross estate comprises "all property, real or personal, tangible or intangible, wherever situated", to the extent provided in sections 2033 through 2045 (i.e., subtitle B, chapter ll, subchapter A, part III of the Code). Section 2033 states broadly that "The value of the gross estate shall include the v

The value of a gross estate includes all of a decedent's property to the extent provided under sections 2033 through 2045. Sec. 2033. At issue here is whether certain property decedent transferred during his lifetime is included in his gross estate under sections 2035(a) and 2036(a) and (b). I. Burden of Proof The estate argues that unde

One of those deductions is for claims against the estate that are enforceable under State law. Sec. 2053(a)(3); Propstra v. United States, 680 F.2d 1248, 1254-1255 (9th Cir. 1982). An estate may deduct the value of a claim based on a decedent's promise to pay only if the liability was contracted bona fide and for full and adequate consid

Section 2031(a) specifies that the gross estate comprises "all property, real or personal, tangible or intangible, wherever situated", to the extent provided in sections 2033 through 2045 (i.e., subtitle B, chapter 11, subchapter A, part III of the Code). Section 2033 states broadly that "The value of the gross estate shall include the v

The value of a gross estate includes all of a decedent’s property to the extent provided under sections 2033 through 2045. Sec. 2033. At issue here is whether certain property decedent transferred during his lifetime is included in his gross estate under sections 2035(a) and 2036(a) and (b). I. Burden of Proof The estate argues that unde

The gross estate generally includes the value of any property with respect to which the decedent has a general power of appointment at the time of his or her death. Sec. 2041(a)(2). With exceptions inapplicable here, a general power of appointment is defined as a power that is exercisable in favor of the decedent, the decedent’s estate,

Section 2051 defines the value of the taxable estate as the gross estate less deductions. “For estate taxes, as for income taxes, ‘Deductions are a matter of legislative grace, and a taxpayer seeking the benefit of a deduction must show that every condition which Congress has seen fit to impose has been fully satisfied.’” Estate of Nicholson v. Com

In turn, the gross estate includes “all property, real or personal, tangible or intangible, wherever situated” to the extent provided in sections 2033 through 2045. Sec. 2031(a). Section 2033 provides that “The gross estate shall include the value of all property to the extent of the interest therein of the decedent at the time of his de

The gross estate includes all property interests owned by the decedent at death; the value of the gross estate is generally the fair market value of the included property as of the valuation date, which is generally the date of death. See secs. 2031(a), 2033; sec. 20.2031-1(b), Estate Tax Regs. 13 Although described as the life insurance

Section 2031(a) specifies that the gross estate comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2033 broadly states that “The value of the gross estate shall include the value of all property to the extent of the interest therein of the d

Section 2051 defines the value of the taxable estate as the gross estate less deductions. “For estate taxes, as for income taxes, ‘Deductions are a matter of legislative grace, and a taxpayer seeking the benefit of a deduction must show that every condition which Congress has seen fit to impose has been fully satisfied.’”5 5 For the first time in t

2051; see Estate of Armstrong v. Commissioner, 119 T.C. 220 (2002). Section 2056(a) allows a marital deduction from a decedent’s gross estate for the value of the property interests passing from the decedent to a decedent’s surviving spouse. Estate of Clack v. Commissioner, 106 T.C. 131, 137 (1996). - 11 - A marital deduction generally is not

Section 2031(a) specifies that the gross estate comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2033 broadly states that “The value of the gross estate shall include the value of all property to the extent of the interest therein of the d

The gross estate includes, to the extent provided in various Code sections (including section 2035), the value at the time of a decedent’s death of “all property, real or personal, tangible or intangible, wherever - 16 - situated.” Sec. 2031(a). This does not mean, however, as the estate implies, that each constituent element of the gro

Section 2031(a) - 23 - specifies that the gross estate comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2033 broadly states that “The value of the gross estate shall include the value of all property to the extent of the interest therein

Generally, under section 2033, the gross estate includes the value of all property to the extent of a decedent's interest therein at the time of death. In particular, the question we consider is governed by section 2040(a), which, in pertinent part, provides: SEC. 2040 (a). General Rule.--The value of the gross estate shall include the v

The parties in this case disagree as to whether decedent’s gross estate includes (1) the value of interests in family limited partnerships and in the corporate general partner of those partnerships that decedent possessed at death or transferred prior to death (and if so, the value of such interests), or (2) pursuant to section 2036(a),

The gross estate of a decedent is determined by including the value (at the date of the decedent's death) of the decedent's interest in all property, real.or personal, tangible or intangible, wherever situated. Secs. 2031(a) , 2033. In this case, one of the issues presented is dete(cid:0)576miriin4g(for purposes of determining the value

The gross estate includes, to the extent provided in various Code sections (including section 2035), the value at the time of a decedent’s death of “all property, real or personal, tangible or intangible, wherever situated.” Sec. 2031(a). This does not mean, however, as the estate implies, that each constituent element of the gross estat

Section 2031(a) then specifies that the gross estate comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2033 broadly states that “The value of the gross estate shall include the value of all property to the extent of the interest therein of

The term “taxable estate” is defined in section 2051 as the value of the “gross estate” less applicable deductions.

Section 2031(a) then specifies that the gross estate comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2042 governs the treatment of life insurance proceeds and provides in relevant part as follows: SEC. 2042. PROCEEDS OF LIFE INSURANCE. Th

The value of the gross estate includes the value of all property to the extent of the decedent's interest therein at the time of - 15 - his death. See sec. 2033. We look to State law to interpret interests and rights. See Tracy v. Commissioner, 70 T.C. 397, 402 (1978); cf. Helvering v. Stuart, 317 U.S. 154, 161 (1942). As relevant to th

All property interests owned by the - 60 - decedent at death are included in the gross estate; the value of the gross estate generally is determined as of the date of death. See secs. 2031(a), 2033; sec. 20.2031-1(b), Estate Tax Regs. Fair market value is the standard for determining value of transfers of property subject to Federal est

Section 2031(a) then specifies that the gross estate - 8 - comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2033 broadly states that “The value of the gross estate shall include the value of all property to the extent of the interest ther

Section 2031(a) then specifies that the “value of the gross estate of the decedent shall be determined by including to the extent provided for in this part [sections 2031 through 2046], the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated.” In this connection, section 2033 broadl

All property interests owned by the - 60 - decedent at death are included in the gross estate; the value of the gross estate generally is determined as of the date of death. See secs. 2031(a), 2033; sec. 20.2031-1(b), Estate Tax Regs. Fair market value is the standard for determining value of transfers of property subject to Federal est

Section 2031(a) then specifies that the gross estate comprises “all property, real or personal, tangible or intangible, wherever situated”, to the extent provided in sections 2033 through 2045. Section 2033 broadly states that “The value of the gross estate shall include the value of all property to the extent of the interest therein of

Section 2033 provides that a decedent’s gross estate includes “the value of all property to the extent of the interest therein of decedent at the time of his death.” In the instant case, we must decide whether the gifts made to decedent’s daughter-in-law and grandchildren pursuant to the order, but after decedent's death, are includable

Federal estate taxes are not a permissible deduction from the gross estate. The value of the gross estate generally includes the value of all property to the extent of the interest therein of the decedent at the time of his death. Secs. 2031, 2033. Petitioner "acknowledges the power of the federal government to impose an estate tax", but

Section 2053 allows a deduction for certain expenses, indebtedness, and taxes. Section 2054 allows a deduction for certain losses. Section 2055 allows a deduction for certain transfers for public, charitable, or religious uses. Section 2056 allows a deduction for certain bequests to a surviving spouse. Nowhere in the Code or regulations

The taxable estate is defined in section 2051 as the gross estate less deductions.

Estate Tax Deduction for Charitable Transfer In determining the value of the taxable estate under section 2051, section 2055(a) allows a deduction from the gross estate of the value of all "bequests, legacies, devises, or transfers" of property to, or for the use of, a wide range of charitable, religious, and educational organizations.

Section 2051 defines the taxable estate as the gross estate less deductions. Section 2031 provides that the gross estate generally comprises all of the decedent's property, real or personal, tangible or intangible, wherever situated. Section 2033 states in very broad terms: "The value of the gross estate shall include the value of all property to t

Section 2051 defines the value of the taxable estate as the gross estate less deductions. Section 2056(a) allows a Federal estate tax marital deduction from a decedent's gross estate for the value of property interests passing from the decedent to the surviving spouse. As a general rule, the marital deduction is reduced by estate succession, legacy

Section 2053 allows a deduction for certain expenses, indebtedness, and taxes. Section 2054 allows a deduction for certain losses. Section 2055 allows a deduction for certain transfers for public, charitable, or religious uses. Section 2056 allows a deduction for certain bequests to a surviving spouse. Nowhere does the Code or regulation

The taxable estate is defined in section 2051 as the gross estate less deductions.

Section 2051 defines taxable estate as the gross estate less deductions. "The value of the gross estate shall include the value of all property to the extent of the interest therein of the decedent at the time of his death." Sec. 2033. Whether decedent had an interest in property at the time of her death is governed by State law. Estate of Gamble v

Section 2054 allows a deduction from the value of the gross estate for losses incurred during the settlement of the estate arising from fires, storms, shipwrecks, or other casualties, or from theft, when such losses are not compensated for by insurance or otherwise. In Estate of Shlensky v. Commissioner, T.C. Memo. 1977-148, this Court s

Section 2051 defines taxable estate as the gross estate less deductions. Section 2056(a) provides: (a) Allowance of Marital Deduction.--For purposes of the tax imposed by section 2001, the value of the taxable estate shall, except as limited by subsection (b), be determined by deducting from the value of the gross estate an amount equal to the valu